South Africa Case Law

Flower v Commissioner for the South African Revenue Service (IT 25209)

Flower v Commissioner for the South African Revenue Service (IT 25209) [2025] ZATC 3 (3 February 2025)

Court

Tax Court

Case number

IT 25209

Judge

Crutchfield

The Tax Court held that SARS’s rule 31 statement impermissibly novated the assessment, allowed Flower’s pre-trade development fees, and rejected ring-fencing.

• Pre Trade Expenditure
• Deductibility Of Development Fees
• Section 11a Income Tax Act
• Section 24j Income Tax Act
• Rule 31 Tax Court
• Ring Fencing